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#2131502 - 05/23/17 03:59 PM
Re: HMDA Notice
peony
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100 Club
Joined: Jan 2017
Posts: 214
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We will be updating our notice using the "suggested" text.
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#2132996 - 06/02/17 09:18 PM
Re: HMDA Notice
peony
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100 Club
Joined: Jan 2004
Posts: 161
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When do you plan on posting the new notice?
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#2132998 - 06/02/17 09:46 PM
Re: HMDA Notice
peony
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100 Club
Joined: Jan 2017
Posts: 214
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We have the new notice scheduled to printed in January and to be in all locations by the end of February.
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#2133004 - 06/02/17 11:39 PM
Re: HMDA Notice
peony
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Diamond Poster
Joined: Dec 2013
Posts: 1,399
CA
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ours will be printed end of the year and put up Jan or Feb
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The opinions expressed are mine, do not represent the opinions of my employer, and they are not to be taken as legal advice.
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#2140620 - 08/03/17 02:59 PM
Re: HMDA Notice
peony
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New Poster
Joined: Oct 2016
Posts: 20
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Question with the new HMDA Rules coming in January of 2018, one of the requirements is for a new lobby poster to be displayed in each lobby and branch. In addition to the new poster, you must provide a written notice to the public upon request. Does anyone believe that this requires a “take-on†kind of notice that the customer take as needed, as WKFS is saying? I have never seen this before and we have always just had the poster and the notice on our website. Thank you in advance for your thoughts. http://www.wolterskluwerfs.com/regulatory-analytics/hmda-poster.aspx
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#2140721 - 08/03/17 08:53 PM
Re: HMDA Notice
peony
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10K Club
Joined: Nov 2000
Posts: 18,762
Central City, NE
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§1003.5(e) states: Posted notice of availability of data. A financial institution shall post a general notice about the availability of its HMDA data in the lobby of its home office and of each branch office physically located in each MSA and each MD. This notice must clearly convey that the institution's HMDA data is available on the Bureau's Web site at www.consumerfinance.gov/hmda.Can you tell me where the regulation requires a "take-one" notice? I read the WK notice, but don't agree.
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#2140766 - 08/04/17 12:51 PM
Re: HMDA Notice
David Dickinson
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New Poster
Joined: Oct 2016
Posts: 20
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That is exactly what I'm trying to find out and I don't agree either. I have never seen a "take-one" requirement. Not sure where they got that from, just wanted to make sure I wasn't missing anything.
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#2141154 - 08/08/17 02:14 AM
Re: HMDA Notice
peony
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Power Poster
Joined: Oct 2000
Posts: 5,991
Soaring over Georgia
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Opportunity for WK to sell pad refills. Definitely not required.
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Jim Bedsole, CRCM, CBA, CFSA, CAFP My posts - my opinions
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#2141165 - 08/08/17 12:22 PM
Re: HMDA Notice
peony
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Platinum Poster
Joined: Sep 2015
Posts: 500
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Beech is so right - I feel like they were once a trusted company but now they're leaning towards profit more than expectations.
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#2144148 - 08/29/17 09:14 PM
Re: HMDA Notice
peony
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Power Poster
Joined: Aug 2006
Posts: 4,266
Chillin an grillin
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On page 90 of the SEG Section 6.3.2 Modified LAR
"Beginning in 2018, upon request from a member of the public, a Financial Institution must provide a written notice regarding the availability of its modified LAR........................."
It goes on to say that we may use the sample notice language and then states that the notice must be made available in paper or electronic form. Comment 5(c)-1.
So does this not seem like we should be handing them a notice either on paper or electronically?
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#2144592 - 08/31/17 08:40 PM
Re: HMDA Notice
peony
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10K Club
Joined: Oct 2000
Posts: 40,086
Cape Cod
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1003.5(b)(2) and 1003.5(c)(1), taken with 1003.5(d).
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John S. Burnett BankersOnline.com Fighting for Compliance since 1976 Bankers' Threads User #8
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#2151218 - 10/26/17 01:24 PM
Re: HMDA Notice
John Burnett
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Platinum Poster
Joined: Jun 2001
Posts: 644
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Just to clarify, we do need to remove our old HMDA lobby notice and replace it with the revised notice that includes the CFPB's website as of 1/1/18, correct?
I ask because technically the modified LAR for 2017 and earlier would be obtained from the bank rather than the CFPB's website so the revised notice seems to be somewhat misleading.
Thanks!!
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#2151241 - 10/26/17 02:43 PM
Re: HMDA Notice
peony
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Platinum Poster
Joined: Jun 2014
Posts: 562
Petersburg, VA
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We are posting only the new notice starting 1/1/2018.
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#2151246 - 10/26/17 02:52 PM
Re: HMDA Notice
burke116
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Gold Star
Joined: Apr 2013
Posts: 420
VA
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We are posting only the new notice starting 1/1/2018. We are doing the same. The way I see it is as of 1/1/2018, the old notice language is gone from the regulation, so any requirement to keep it up is gone as well.
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The answers I give are my opinions. Not legal advice.
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#2152447 - 11/06/17 10:23 PM
Re: HMDA Notice
peony
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100 Club
Joined: Jan 2013
Posts: 169
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So informal poll. Are most just posting the current notice and not concerning themselves with how they get data for years prior to 2017? Was thinking about adding a blurb in the updated notice to say "data for years prior to 2017 are available by inquiring at this office" or something similar to that. What are you guys doing to address the gap? Or is everyone taking the stance NSF outlined that this is no longer in the reg so it is no longer a concern?
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CRCM
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#2152449 - 11/06/17 10:25 PM
Re: HMDA Notice
peony
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Platinum Poster
Joined: Apr 2014
Posts: 673
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We are just posting the notice that refers them to the CFPB.
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Define Success on your own terms, achieve it by your own rules, and build a life you are proud of. Anne Sweeney
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#2156309 - 12/06/17 08:16 PM
Re: HMDA Notice
peony
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Member
Joined: Jan 2012
Posts: 70
New York
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I am reading here that we are required to provide the HMDA notice to the requester "in hand". Isn't this required if they ask for the modified LAR? Am I reading the Small Entity Guide wrong?
6.3.2 Modified LAR Effective January 1, 2018, the HMDA Rule changes a Financial Institution’s obligations with respect to disclosing its modified LAR. The new requirements apply to data collected in 2017 and later years. Beginning in 2018, upon request from a member of the public, a Financial Institution must provide a written notice regarding the availability of its modified LAR.
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#2156472 - 12/07/17 05:59 PM
Re: HMDA Notice
Kathleen O. Blanchard
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10K Club
Joined: Nov 2000
Posts: 18,762
Central City, NE
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Just having a poster is not enough. The disclosure notice must be given to anyone requesting the 2017 or forward LAR or disclosure statement. They must walk away with something in their hand. You can also email them the notice.
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